EML Payments found a small hole in the PFS boat and have addressed it. They are being pro-active - actively looking for and fixing problems. Where there is one problem there can be more.

A little voice says, "We can regulate ourselves by ourselves, just give us time to fix problems caused by someone else".

Ref: 19th of May announcement: Central Bank of Ireland correspondence

Due to Brexit, PFS Ireland had to transfer non UK programs (European programs) from the FCA regulated authority to the CBI regulated authority. It could easily be argued, the CBI would be negligent if they decided to not look. The CBI say they are “minded” to look. This suggests an obligation - rather than suspicion or identification of an actual problem. So the CBI has “invited” the company to provide it with submissions in relation to “the concerns”.

The concerns (money laundering / anti terrorism) relate to identification. Each prepaid card (physical or digital) must be tied to the identity of the purchaser. This allows value to be stored and transferred with accountability. As suggested by CBI in their letter (14th May), non-compliance would raise “significant regulatory concerns”. The risks appear to be well known and documented.